Thomas and Janice Gleason - Page 20

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               The parties stipulated that petitioners alleged a $7,842,696           
          basis in Alofs, calculated as follows:                                      
               $50,000   Cash contribution with initial ownership of 20%              
               6,000,000 Loan from taxpayer through Comerica bank                     
               500,000   Loan from selling shareholders backed by CD from taxpayer    
               196,000   Sales price reduction of Excellence                          
               696,696   Portion of the sales proceeds from Excellence                
               400,000   Loan from Excellence to Alofs                                
          Respondent disallowed most of these amounts and determined a                
          basis in Alofs of $877,574, comprising the $50,000 contribution,            
          $356,760 in sales proceeds from Excellence, and the $470,814                
          shown on the Schedule K-1 from Alofs for FYE 1995.                          
               The parties likewise stipulated that petitioners alleged on            
          audit a basis in Target of $2,138,304, which amount included the            
          initial investment of $35,000 and $2,103,304 in sales proceeds              
          from Excellence.  Respondent, in contrast, computed a basis in              
          Target of $584,133:                                                         
               $35,000  Initial investment                                            
               1,070,279  Portion of sales proceeds from Excellence                   
               (616,947) Loss for FYE 1995                                            
               (70,163) Property distribution for FYE 1994                            
               113,311  Income for FYE 1993                                           
               (42,242) Loss for FYE 1992                                             
               101,485  Income for FYE 1991                                           
               5,675  Income for FYE 19905                                            
               (12,265) Loss for FYE 1989                                             
          Incorporated in both parties’ computations as sales proceeds from           
          Excellence are the basis amounts transferred to Alofs and Target            
          upon the exchange of Excellence shares for those in Alofs and               

               5 Although the stipulation refers to $5,673 as the amount              
          from the pertinent Schedule K-1, this would appear to be a                  
          typographical error.                                                        





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